Ratson Advisory LLC

Item 5. Fees and Compensation
      RA offers investment management services in return for management fees. RA’s management fees typically
      are either a fixed fee, or a fee based on the amount of assets under the Firm’s management or advisement.
      For management fees based on assets under management or advisement, the fee rate applies and varies
      between 35 and 150 basis points (0.35% – 1.50%), depending upon the size and composition of a client’s
      portfolio and the type and amount of services rendered.

      The Management fees are typically structured as an annual fee and are prorated and charged monthly, in
      arrears. For assets under management based fees, the monthly fee amount is based upon the market value
      of the assets being managed by RA on the last day of the month. For marketable securities and cash, the
      value is typically determined by reference to values obtained from a party independent from the Firm
      (including the client’s custodian or another third-party). For any less-liquid or illiquid assets subject to
      asset-value based fees, if there is no third-party or client-provided market value, the Firm determines a
      fair value for the asset according to its valuation policies and procedures. The Firm typically manages
      the assets of pooled investment vehicles as a sub-adviser. In those circumstances, the billing procedures
      (including the timing) will be structured to conform to the terms of the particular pooled investment
      vehicle’s offering documents.

      In the event the advisory agreement is terminated, the fee for the final billing period is prorated through
      the effective date of the termination and the outstanding or unearned portion of the fee is charged or
      refunded to the client, as appropriate.

      Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
      held-away assets, accommodation accounts, alternative investments, etc.), RA can negotiate a different flat
      fee, or an AUM-based fee rate that differs from the range set forth above. Clients are advised that a conflict
      of interest exists for the Firm to recommend that clients engage RA for additional services for
      compensation, including rolling over retirement accounts or moving other assets to the Firm’s management.
      Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation
      to act upon any of the recommendations.

      Fee Discretion

      RA may, in its sole discretion, negotiate to charge certain clients a lesser fee based upon certain criteria,
      such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
      be managed, related accounts, account composition, pre-existing/legacy client relationship, account
      retention, pro bono activities, or competitive purposes.

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 Disclosure Brochure                                                                  Ratson Advisory LLC

      Additional Fees and Expenses

      In addition to the advisory fees paid to RA, clients also incur certain charges imposed by other third parties,
      such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively
      “Financial Institutions”). These additional charges include securities brokerage commissions, transaction
      fees, custodial fees, fees attributable to alternative assets, reporting charges, margin and other borrowing
      costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s
      prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
      differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
      accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12,
      below.

      Use of Margin

      RA can be authorized by clients to use margin in the management of the client’s investment portfolio. In
      these cases the fee payable will be assessed gross of margin such that the market value of the client’s
      account and corresponding fee payable by the client to RA will be increased. Where investment
      management fees are assessed gross of margin, a conflict of interest exists as the Firm has an incentive to
      use margin to increase its fees.

      Account Additions and Withdrawals

      Clients can make additions to and withdrawals from their account at any time, subject to RA’s right to
      terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to
      liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients
      can withdraw account assets on notice to RA, subject to the usual and customary securities settlement
      procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets
      may impair the achievement of a client’s investment objectives. RA may consult with its clients about the
      options and implications of transferring securities. Clients are advised that when transferred securities are
      liquidated, they may be subject to third-party transaction fees, short-term redemption fees, fees assessed at
      the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.

Item 7. Types of Clients
      RA offers services to individuals, families, pooled investment vehicles, banking institutions and other
      institutional clients.